Faith Haines v. New Jersey Department of Corrections

CourtNew Jersey Superior Court Appellate Division
DecidedFebruary 5, 2026
DocketA-0035-24
StatusUnpublished

This text of Faith Haines v. New Jersey Department of Corrections (Faith Haines v. New Jersey Department of Corrections) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Faith Haines v. New Jersey Department of Corrections, (N.J. Ct. App. 2026).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited . R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-0035-24

FAITH HAINES,

Appellant,

v.

NEW JERSEY DEPARTMENT OF CORRECTIONS,

Respondent. ___________________________

Submitted December 9, 2025 – Decided February 5, 2026

Before Judges Gilson and Perez Friscia.

On appeal from the New Jersey Department of Corrections.

Faith Haines, self-represented appellant.

Matthew J. Platkin, Attorney General, attorney for respondent (Christopher Weber, Assistant Attorney General, of counsel; Joseph D. Sams, Deputy Attorney General, on the brief).

PER CURIAM Faith Haines, who is incarcerated in a correctional facility, appeals from

a final agency decision by the Department of Corrections (Department), which

determined she had no right to administratively appeal an on-the-spot-correction

(OTSC), which resulted in a verbal reprimand. Haines argues her due process

rights were violated because she was not accorded an appeal. She also contends

that she was deprived of procedural rights during the hearing that resulted in her

OTSC and reprimand.

Because Haines' discipline did not subject her to a "grievous loss" of rights

and because we discern nothing arbitrary, capricious, or unreasonable in the

Department's application of its regulation, which states that there is no right of

an appeal beyond a conference for an OTSC, see N.J.A.C. 10A:4-7.2(e), we

affirm the Department's decision. Given that ruling, Haines has no right to

challenge the OTSC determination before us because we do not consider

decisions by a Department hearing officer. Instead, appeals to us are from the

final decision of the agency. See R. 2:2-3(a)(2).

I.

The facts giving rise to this appeal are not complicated. On July 23, 2024,

a corrections officer observed crumbs and several open bowls containing

chicken and other "food items" on Haines' bed. The officer also saw "ants

A-0035-24 2 crawling all over the food and bed area." Haines was charged with committing

prohibited act .651, "being unsanitary or untidy; failing to keep one's . . . quarters

in accordance with posted standards" in violation of N.J.A.C. 10A:4-

4.1(a)(5)(xiii).

The following day, the charge report was delivered to Haines. Haines pled

not guilty and was assigned a counsel substitute. She then obtained and

submitted a written statement from her cell mate.

A Department hearing officer conducted a hearing on July 26, 2024. The

hearing officer considered statements from Haines, her cell-mate, the officer

who observed the food and ants, and another officer who served the charges on

Haines. Based on that evidence, the hearing officer found Haines guilty of

committing prohibited act .651, downgraded the violation to an OTSC, and

issued Haines a verbal reprimand.

Haines filed an administrative appeal from the hearing officer's decision.

On July 29, 2024, her appeal form was returned to her, and she was informed

that she could not appeal an OTSC determination.

Haines now appeals from the Department's determination that she had no

right to an administrative appeal. She argues that the Department's failure to

accord her an administrative appeal violates her due process rights. She also

A-0035-24 3 contends that her due process rights were violated at the hearing because her

request to review a video recording was denied and her right to cross-examine

the charging officer was also denied.

A. The Right to An Appeal.

OTSCs are considered "minor" disciplinary matters. N.J.A.C. 10A:4-

7.2(e); see also Avant v. Clifford, 67 N.J. 496, 518-19 (1975) (recognizing that

OTSCs are "minor infractions"). An OTSC adjudication subjects an inmate to

limited sanctions, including a verbal reprimand, limited loss of privileges, up to

four hours of confinement to "the room or housing area[,]" and "up to four hours

of extra work duty[.]" N.J.A.C. 10A:4-7.3. The Department accords limited

review of an OTSC. In that regard, the Department regulations state, in relevant

part:

The custody staff supervisor shall hold a conference within [twenty-four] hours of receipt of the On-The- Spot Disciplinary Report/Adjudication. The inmate shall also be afforded the right to appear at the conference with the custody staff supervisor at which time the inmate may review and appeal the disciplinary report, discuss the violation and the inmate may present arguments regarding disciplinary action and challenge the proposed sanction.

....

At the conclusion of the conference, the inmate shall receive a completed copy of the On-The-Spot

A-0035-24 4 Disciplinary Report/Adjudication. Should the inmate be found guilty, a copy of the report shall be submitted to the Correction Major.

[N.J.A.C. 10A:4-7.2(a) and (d).]

The regulations also state: "On-the-spot disciplinary action is considered minor

in nature and as such the right afforded to the inmate to appear at the conference

shall be the final appeal for a finding of guilt to an on-the-spot disciplinary

adjudication." N.J.A.C. 10A:4-7.2(e). N.J.A.C. 10A:4-7.2 was adopted in 1986

and was last revised in May 2021.

The law is well-established that prisoners have limited due process rights.

Avant, 67 N.J. at 529-30; Blanchard v. N.J. Dep't of Corr., 461 N.J. Super. 231,

239-40 (App. Div. 2019). Those limited due process rights, moreover, attach

and apply only to "disciplinary matters which may subject an individual to

'grievous loss' by way of punishment for serious misconduct." Avant, 67 N.J. at

519 (quoting Morrissey v. Brewer, 408 U.S. 471, 481 (1972)). Accordingly, due

process rights do not apply to OTSCs. See Avant, 67 N.J. at 518-19. Indeed,

when the New Jersey Supreme Court established the limited due process rights

that must be accorded to prisoners in serious disciplinary matters, it expressly

stated that it was not "concerned . . . with disciplinary response[s] to minor

infractions, sometimes called 'On-The-Spot-Correction' involving slight

A-0035-24 5 punishment such as verbal reprimand, temporary withdrawal of privileges, or

brief confinement to tier[.]" Id. at 518.

Given that Haines' charge was downgraded to an OTSC and she was given

a verbal reprimand, we discern no due process violation in the Department's

decision to follow its regulations and not allow an administrative appeal beyond

the hearing conducted by the neutral hearing officer. Moreover, we discern

nothing arbitrary, capricious, or unreasonable in the Department's application of

its regulation. In that regard, we note that those regulations have existed for

several years and Haines can only challenge them as applied to her particular

situation. See N.J.S.A. 52:14B-4(d); Bergen Pines Hosp. v. Dep't of Hum.

Servs., 96 N.J. 456, 471 n.9 (1984) (explaining "[t]he Administrative Procedure

Act provides that a proceeding to contest any rule . . . must be made within one

year from the effective date of the rule").

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Related

Morrissey v. Brewer
408 U.S. 471 (Supreme Court, 1972)
Bergen Pines County Hospital v. New Jersey Department of Human Services
476 A.2d 784 (Supreme Court of New Jersey, 1984)
Avant v. Clifford
341 A.2d 629 (Supreme Court of New Jersey, 1975)

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Faith Haines v. New Jersey Department of Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/faith-haines-v-new-jersey-department-of-corrections-njsuperctappdiv-2026.